HB5346, titled the Fair and Accountable IRS Reviews Act, would amend the Internal Revenue Code to change how certain IRS penalties are approved before they can be assessed. Under the bill, no penalty could be assessed or entered unless the initial determination is personally approved in writing by the immediate supervisor of the IRS employee making the determination, or by a higher-level official designated by the Secretary, and that approval must occur before any written communication about the penalty is sent to the taxpayer.
The bill also defines “immediate supervisor” as the person to whom the employee reports, which is intended to clarify who must provide the required approval. The changes would apply only to notices issued and penalties assessed after December 31, 2025, making the measure prospective rather than retroactive.
Impact
The bill would amend Section 6751(b) of the Internal Revenue Code of 1986, tightening procedural requirements for IRS penalty assessments and adding a statutory definition of “immediate supervisor.” In practical terms, it would impose an additional approval step before the IRS can communicate or assess penalties, potentially affecting IRS enforcement procedures, taxpayer penalty disputes, and administrative review practices. The bill does not change tax rates or create new penalties; it changes the internal authorization process for existing penalties.
Sentiment
Based on the available context, the bill appears to have advanced in the House and then been received in the Senate and referred to the Senate Finance Committee, suggesting at least some legislative support for the proposal. The title and structure indicate a reform-oriented approach focused on accountability and oversight of IRS penalty decisions. No committee transcript or vote breakdown is available, so the record does not show detailed debate or the level of bipartisan support or opposition.
Contention
The main point of contention is likely to be whether the added supervisory approval requirement improves taxpayer protections and accountability or instead creates unnecessary administrative burden and slows IRS enforcement. Supporters would likely emphasize due process, consistency, and preventing overreach in penalty assessments, while critics may argue that the rule could complicate routine tax administration and reduce agency efficiency. Because no hearing transcript or vote details are provided, specific named opponents or supporters cannot be identified from the record.